PRIVACY POLICY

Last updated: 8th of August, 2020

This Privacy Policy governs the manner in which Agenome collects, uses, maintains, and discloses information collected from the users of Agenome.

Information we collect

Event and usage data When you visit our website, our servers process data in order to
understand your usage of our Services—for example, which pages you visit or which tab in the website you open. We collect this information and use it as aggregate data to better understand which features are the most relevant or useful to our users.

IP address We collect IP addresses provided by your browser to deliver the Service to your
device. We also use the IP address to determine your approximate location for statistical and
analytics purposes.

All the data we collect is necessary to deliver the Services you use. The amount of data we
collect has been minimized wherever possible to respect your privacy. Should you still disagree with the collection and processing of this data, we recommend you stop using our Services or delete your account.

Health-related and biometric information that you upload to Agenome is considered as being
sensitive personal data. We do not store sensitive personal data without your explicit
permission. It is only when you give us explicit consent by creating a Agenome account then we start storing all your health and sensitive data on our secured HIPAA compliant servers,
alongside the personal data necessary to create an account.

You can withdraw your consent at any time by simply deleting your account on your profile page or by using the feedback form. We will permanently delete your account, and remove all your data.

Here is the type of data we collect and store when you create an account:

Personal data used for account creation
We need some of your personal data, such as your email address, in order to create your Agenome account.

Health-related and sensitive data
We store health-related and biometric information including your body measurements, blood
test values, heart rate and other information.

How we use your information

1. To provide you with Services and analyze and improve our Services
We use the information described above to operate, provide, analyze and improve our Services. These activities may include, among other things, using your information in a manner consistent with other commitments in this Privacy Statement, to:

● open your account, communicate with you, and implement your requests;
● host our website, authenticate your visits, provide custom, personalized content and
information, and track your usage of our Services;
● contact you about your account, and any relevant information about our Services (e.g. policy changes, security updates or issues, etc.);
● enforce our Terms of Service and other agreements;
● monitor, detect, investigate and prevent prohibited or illegal behaviors on our Services, to
combat spam and other security risks; and
● perform research & development activities, which may include, for example, conducting data analysis and research in order to develop new or improve existing products and Services, and performing quality control activities.

2. To process, analyze and deliver your testing results
We process the information described above to provide our Services. This includes processing your blood test data, photo and other data submitted to our forms and surveys to provide you with personalized reports. We continuously work to improve our Services based on our research and product development. You will be notified of additional reports or otherwise improved reports in future.

3. To provide customer support
When you contact Customer Care, we may use or request personal information and/or sensitive information as necessary to answer your questions, resolve disputes, or troubleshoot problems.

Disclosure of your data

Cloud storage, IT, and Security
Our cloud storage providers provide secure storage for information in Agenome databases,
ensure that our infrastructure can support continued use of our Services by Agenome customers, and protect data in the event of a natural disaster or other disruption to our
Services.
1. Aggregate information
We may share de-identified, aggregate information, which is information that has been stripped of your name and contact information and combined with information of others so that you cannot reasonably be identified as an individual, with third parties. This is not personal information because it does not identify any particular individual or disclose any particular individual’s data, or disclose any particular individual’s. We may disclose aggregated information or other non-personal information without restriction.

As required by law
Under certain circumstances your personal information may be subject to processing pursuant to laws, regulations, judicial or other government subpoenas, warrants, or orders. Agenome will preserve and disclose any and all information to law enforcement agencies or others if required to do so by law or in the good faith belief that such preservation or disclosure is reasonably necessary.

Your consent for processing health and sensitive data

If you create an account with Agenome, your personal data—including sensitive data and data related to your health—is stored and processed on Agenome servers. This is done so we can offer you the option of backing up your data and to provide Services.
By creating an account with Agenome you explicitly consent that:

i. Agenome may store and process personal data you provide through the usage of the Agenome website and through the account creation process solely for the purpose of providing Agenome services to you and to improve our Service features. Such Agenome Services may include sending you information and reminders to the email address you provided to Agenome.

ii. Personal data you provide to Agenome through the account creation process includes personal data you enter into the Agenome website, such as your account data (e.g. your name and email address), and your sensitive data. Depending on the data you provide, it may also contain information about your general health.

iii. Agenome will not transmit any of your personal data to third parties, except if it is
required to provide the Agenome Service to you (e.g. technical Service providers), unless Agenome has asked for your explicit consent.

iv. Agenome may use your data to create anonymized sets of data for academic and
clinical research purposes. This anonymized research data cannot be linked to you as an individual or identify you in any way.

We store a record of the signed registration form with your explicit consent to data processing. You may withdraw your consent to this use of your data at any time by deleting your Agenome account.

Your rights

We believe that data privacy and data protection are fundamental human rights. At Agenome we strive to ensure that your rights are respected. Here are some key facts about your privacy that we would like you to know:

i. Our products and Services have been designed to minimize the use of your personal data.
We only collect and process your data for the purposes that have been previously outlined.
ii. The security of our servers is regularly verified by experts to protect your data from
unauthorized access. You can contact us at a@agenome.tech if you have any
questions about the security of our Services.
iii. We do not retain your data in an identifiable format for longer than necessary to deliver our Services.
iv. Agenome does not engage in any automated decision-making or profiling activities. As a user of Agenome Services and website, you may exercise your user rights to:
i. Request information on your personal data processed by Agenome. Upon your request, this information will be provided to you electronically.
ii. Gain access to your information by requesting a backup of your data (as explained in the next section) in a format that is readable by other companies or organizations.
iii. Correct your personal information and sensitive data.
iv. Withdraw your consent from data processing at any time by deleting your account.
v. Lodge a complaint with the relevant supervising authority if you believe Agenome is
processing your personal data under violation of applicable data protection regulations.
vi. Request us to delete the personal identifiable personal information we hold about you.

Data Security

We apply security measures to protect against the misuse, loss, and/or alteration of personal
information under our control. We follow industry best practices when transferring and storing your data. Though we cannot ensure or guarantee that misuse, loss or alteration of information will never occur, we use all reasonable efforts to prevent it.

How we store and protect your personal data

The security of your personal information is important to us. We have adopted generally
accepted industry standards in connection with our data collection, storage, and processing
practices and security measures to protect against unauthorized access, alteration, disclosure, or destruction of your personal information, username, password, transaction information, and data stored on the Sites. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, while we strive to use commercially acceptable means to protect your personal information, we cannot guarantee its absolute security.

Your data is transmitted between your device and Agenome servers using the HTTPS protocol for encryption. HTTPS is the same technology used to create secure connections for your web browser and is indicated by a padlock icon in the URL bar of your browser.
The security of our servers is routinely verified by experts to protect your data from unauthorized access. You can contact us at a@agenome.tech if you have any questions about the security of our Services. At Agenome all access to the data is limited to authorized personnel, based on job function and roles. Agenome requires all of our employees to complete security and privacy training on an annual basis.

Cookies

Our website uses cookies, which are small text files that are intended to make the site better for you to use. In general, cookies are used to retain preferences, store information for things like shopping carts, and provide tracking data to third-party applications like Google Analytics. You may, however, disable cookies on Agenome website. The most effective way to do this is to disable cookies in your browser. We suggest consulting the help section of your browser or doing your own web research on how to disable cookies.

Young users

Agenome is not directed to, and we do not knowingly collect or solicit personal information from children under 21. In case we learn we have collected or received personal information from children under the age of 21, we will delete this information.